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house, the defendant indicated others were inside the house and officers saw another person inside).” Overruled to the extent that it “holds that the presence of odors can never be the sole basis for the issuance of a search warrant,” State v. Kazmierczak , 331 Ga.App. 817, 771 S.E.2d 473 (March 30, 2015). Elliot v. State, 274 Ga.App. 73, 616 S.E.2d 844 (June 28, 2005). Protective sweep of motel room was authorized even though defendant came out and shut door before he was arrested. “Based on the information given to the police … about Elliot’s violent nature, officers were justified in thinking that someone in the room might be hurt or held against his or her will. Elliot closed the door after him and would not respond when the officers asked him if anyone else was in the room. An officer testified that he did not know at the time that [defendant’s wife] was safe, and that he believed that Elliot was armed. The officers also did not know whether other people might still be in the motel room, possibly armed. When arrested outside the motel room, no weapon was found on Elliot’s person, but a pistol was later recovered in the room.” Kirsche v. State, 271 Ga.App. 729, 611 S.E.2d 64 (February 21, 2005). Circumstances did not justify a protective sweep: “‘Hall County deputies, responding to a “domestic call” from the defendant’s daughter, found her at the home of a neighbor. She told them that she and her father had had a disagreement about school, that he had gotten irate and that she had gotten scared and left the home. She told the deputies also that her father was growing marijuana in the backyard of their residence.’” Based on this information, narcotics officers were called. Officers approached the back door as lead officer knocked on the front door. It was dark, and “there was nothing about the appearance of the front of the house that indicated it was acceptable to walk around the back.” As indicated by the daughter, the officers found a 10-foot marijuana plant a few feet from the patio behind the house. Officers said they approached the back of the house as a “standard policy under the circumstances … for safety or security reasons.” “[W]e find no case law to support the proposition that an allegation that someone is irate constitutes a compelling reason or an exceptional circumstance that would justify warrantless entry onto a person’s property. See King v. State, 217 Ga.App. 889, 891 (459 S.E.2d 605) (1995) (that defendant was agitated and backed up into his residence did not justify deputy’s advance into home as a response to any perceived safety threat).” Nelson v. State, 271 Ga.App. 658, 610 S.E.2d 627 (February 16, 2005). “A ‘protective sweep’ is a limited search of the premises conducted primarily to ensure the safety of police officers by detecting the presence of other occupants. State v. Mixon, 251 Ga.App. 168, 554 S.E.2d 196 (2001). The seminal United States Supreme Court case authorizing this type of warrantless entry, Maryland v. Buie, 494 U.S. 325, 110 S.Ct. 1093, 108 L.Ed.2d 276 (1990), held that officers are authorized to perform a protective sweep in conjunction with an in-home arrest when they possess ‘articulable facts which, taken together with the rational inferences from those facts, would warrant a reasonably prudent officer in believing that the area to be swept harbors an individual posing a danger to those on the arrest scene.’ Id. at 334(III).” Sweep need not be incident to an arrest, however. Exigent circumstances justified this sweep: “the officers knew that contraband and people were inside the house and … they observed occupants of the house running out the back door.” Reviewed “from the standpoint of a hypothetical ‘reasonable’ officer,” the combination of drug involvement and fleeing persons created a “quickly developing situation” in which the officers “articulated facts sufficient to justify a cursory sweep.” Inglett v. State, 239 Ga.App. 524, 521 S.E.2d 241 (July 28, 1999). Facts justified protective sweep of houses: officers participated in controlled delivery of package containing methamphetamine. Defendant, upon arrest, said she had been promised meth if she accepted delivery of the package. Officers saw more meth and a marijuana cigarette in plain view. “On the basis of [defendant’s] comments and the officers' observation of at least one other individual in the residence, it appeared that there was more than one person on the premises engaged in narcotics trafficking. On the basis of his experience, [officer] testified that where there is a large amount of narcotics ‘there's bound to be guns,’ and numerous guns in fact were found in [co-defendant's] bedroom. Police officers are authorized to make a protective sweep in conjunction with an in-home arrest when they possess “articulable facts which, taken together with the rational inferences from those facts, would warrant a reasonably prudent officer in believing that the area to be swept harbors an individual posing a danger to those on the arrest scene.” Maryland v. Buie, 494 U.S. 325, 334, 110 S.Ct. 1093, 108 L.Ed.2d 276 (1990). It would thus appear that the officers in this case had the grounds needed to justify a protective sweep. And even if they did not, exigent circumstances did permit a cursory search of the house in order to prevent the escape of unknown individuals. See United States v. Rubin, 474 F.2d 262, 268-269(3,4) (3rd Cir., 1973).” Price v. State, 270 Ga. 619, 513 S.E.2d 483 (March 8, 1999). Protective sweep was justified where one resident of apartment lay dead in parking lot, second resident, this defendant, was being arrested, and “the police knew that a third person, Price’s brother, lived at the apartment, and because the police did not know whether he was in the apartment,
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